Hart Council censors questions about the Local Plan

In an astonishing move reminiscent of North Korea or Stalinist Russia, Hart Council have decided to censor questions saying they “do not publish speculative views from the public” and that they will “prepare and publish guidelines on the format of questions that will be accepted”.

This arose because we asked three questions about school places, brownfield sites and whether Hart would consider an alternative approach to delivering the Local Plan.  Each question had a preamble to set the context before the short question was asked.  Hart have decided to censor the preamble part of each question so that members of the public can’t see them, although they did say they circulated the full text to councillors.

There is a saying that the flak gets heaviest when you are over the target, so I guess this means that the council are finding the questions we are asking uncomfortable.  But we are astonished by their attempt to stifle democracy and how they seek to infantilise the debate about the best approach to the Local Plan.

We think the Planning Inspector will take a dim view of this approach as NPPF Para 155 says:

“Early and meaningful engagement and collaboration with neighbourhoods, local organisations and businesses is essential. A wide section of the community should be pro-actively engaged, so that Local Plans, as far as possible, reflect a collective vision and a set of agreed priorities for the sustainable development of the area, including those contained in any neighbourhood plans that have been made.”

This clearly places an obligation on Hart Council to consult widely and they seem to be afraid to engage, even though they asked us to make a submission to the Hop Garden Road (Owens Farm) appeal and were pleased to receive our criticism of the Rushmoor Local Plan.

 

 

 

Hart Council in denial about the Local Plan

Hart Council refuse to acknowledge failings in the Local Plan

Hart Council refuse to acknowledge failings in the Local Plan

Hart Council’s answers to questions put at the council meeting on 30 July reveal a staggering level denial about the status of the Local Plan.  We put some questions to council, but many more questions were put by Winchfield Action Group members.  A lot can be learned from the answers, and in some cases non-answers to the questions put.  The detailed answers can be found here and here, and are summarised below:

  • Hart Council have ruled out again the creation of a register of brownfield sites and have refused to establish a formal “brownfield” option for consideration as part of the Local Plan process.  Hart also refused to consider our proposals for an alternative approach to the Local Plan.
  • They are still working on the project plan for the Local Plan project, and can’t say when the project plan will be available for public scrutiny. Despite not having a project plan, they are hoping the new draft Local Plan will be available by the end of the year.  It is clear that the plan is in some disarray, despite the council insisting as recently as the April meeting that the project was on track.
  • The council is continuing to insist that “many” people in Hart support the new town plan, despite only around 200 people supporting that as their first preference in Hart’s consultation, and over 2,000 people signing the We Heart Hart petition opposing the new town idea.
  • Both Hart and Hampshire Councils have not done any planning for the supply and demand for school places beyond 2018.
  • Hart has no “Plan B” if the new town proposal doesn’t pass testing.
  • The council may allow a further round of consultation on the new draft Local Plan, but have not yet taken a decision on that.

Taken together this is a staggering number of failings and they appear to have no plan to bring the project back on track, even though they still insist that it is imperative the Local Plan is produced quickly.

Fleet News and Mail covers infrastructure costs story

Fleet News and Mail - £300m cost risk to 5000 houses July 16 2015

Fleet News and Mail – £300m cost risk to 5000 houses July 16 2015

We are delighted that Fleet News and Mail has latched on to our story about the massive infrastructure costs of the Local Plan and in particular of a new town in Winchfield.  It is interesting that Hart District Council declined to comment on the story, which appears to mean they don’t dispute any of the figures we put forward, so they must acknowledge that the Local Plan project is in a bit of a hole.

The story was covered in the July 16 issue of Fleet N&M, and an image of the full story can be found here (caution large file).  Hopefully the story will be placed online soon.

Hart Council Responds to Rushmoor’s Local Plan

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough, Rushmoor Borough, Hampshire.

Hart Council has responded to Rushmoor’s Draft Local Plan.  In summary their points are:

  • Rushmoor should look again at the SHLAA to seek out new sites and increase densities
  • Rushmoor should reconsider the scope for using surplus employment sites for housing and also releasing some surplus retail space.
  • Rushmoor should alter its housing target to better reflect its delivery trajectory so that it clarifies that the alleged unmet need comes after 2024, and then commit to a review of the plan to investigate the potential housing shortfall nearer the time.

Hart also suggests that much more dialogue is required between the councils and with the service providers to resolve infrastructure issues.

We Heart Hart broadly welcomes this feedback from Hart Council but believes they could have gone further by asking that the densities on Wellesley be reviewed and even more of the protected 96 Ha of employment land could be released for housing.  Even so, if Rushmoor takes on board Hart’s observations, then Rushmoor will not need to ask Hart to build 1,600 houses for them. This would probably mean a new town at Winchfield is not required.

 

Hart Council on collision course with new Government brownfield planning policies

Hart Council on Collision Course with Government Brownfield Planning Policy

Hart Council on Collision Course with Government Brownfield Planning Policy

Hart District Council has written to local Parish Councils setting out its interpretation of the new Government planning policies set out in the new Productivity Plan.  However, it doesn’t seem to be following this guidance and is on a collision course with Government policy.  Their interpretation is shown below in italics, with our comments in red plain text:

“If you don’t get a Local Plan in place soon the Government will intervene and arrange that they are written for you. We pointed out months ago that the Local Plan project is well behind schedule, but Hart dismissed these concerns. Hart has recently announced it will publish a draft local plan later this year, at least six months behind their original schedule, but it appears set on ignoring our 5-point plan for change.  This additional consultation step is welcome, but it does illustrate the weaknesses in project management and governance.

To speed up the Local Plan process the Government will bring forward streamlined processes

The government will strengthen guidance to improve the operation of the duty to cooperate on key housing and planning issues, to ensure that housing and infrastructure needs are identified and planned for. Hampshire as a whole has a £1.9bn funding deficit, Rushmoor £80m and Hart £78m.  All of these figures are likely to be under-estimates because many of the numbers were compiled before the latest housing allocations were calculated.  Rushmoor has barely mentioned infrastructure in its draft plan and Hart has barely started identifying the infrastructure requirements.

The government will consider how policy can support higher density housing around key commuter hubs. The government will also consider how national policy and guidance can ensure that unneeded commercial land can be released for housing. This is in line with the arguments we have been making about building higher density developments in urban areas, yet Hart is persisting with its new town idea in defiance of government direction.  Indeed, we have used the Employment Land Review evidence to demonstrate that at the end of the plan period there’ll be 195 hectares of vacant employment land across the Housing Market Area yet neither Hart nor Rushmoor appear to be taking this seriously.

The government has already committed to legislating for statutory registers of brownfield land suitable for housing in England. The government will go further by legislating to grant automatic permission in principle on brownfield sites identified on those registers, subject to the approval of a limited number of technical details. On brownfield sites, this will give England a ‘zonal’ system, like those seen in many other countries, reducing unnecessary delay and uncertainty for brownfield development. Hart has refused to even take the first step of a ‘brownfield first’ strategy by ruling out creating a register of brownfield sites. Hart risks being lumbered with poorly designed schemes if it doesn’t take a proactive approach to brownfield sites.

The Government intends tighten the planning performance regime, so that local authorities making 50% or fewer of decisions on time are at risk of having decision making taken away from them.

It legislate to extend the performance regime to minor applications, so that local authorities processing those applications too slowly are at risk having decision making taken away from them

The Government will introduce a fast-track certificate process for establishing the principle of development for minor development proposals, and significantly tighten the ‘planning guarantee’ for minor applications

The Government will introduce a dispute resolution mechanism for section 106 agreements, to speed up negotiations and allow housing starts to proceed more quickly

The government will deliver its commitment to get 200,000 Starter Homes built by 2020, at a 20% discount for young first time buyers. The government is bringing forward proposals to help deliver this commitment, which include:

  • requiring local authorities to plan proactively for the delivery of Starter Homes. Surely, apartments in higher density developments in urban areas will give a much greater opportunity for delivering starter homes.  Yet Hart is eschewing this type of development.

  • extending the current exception site policy, and strengthening the presumption in favour of Starter Home developments, starting with unviable or underused brownfield land for retail, leisure and institutional uses (Good but will be exploited by developers to build on the edges of towns and villages)

  • enabling communities to allocate land for Starter Home developments, including through neighbourhood plans

  • bringing forward proposals to ensure every reasonably sized housing site includes a proportion of Starter Homes (

  • implementing regulations to exempt these developments from the Community Infrastructure Levy, and re-affirming through planning policy that section 106 contributions for other affordable housing, and tariff-style general infrastructure funds, will not be sought for them” We don’t agree with this aspect of Government policy in that all extra housing will create additional demands for infrastructure, so a way needs to be found of funding infrastructure.  However, even the contributions to green field development are not sufficient to cover the costs of additional infrastructure partly because 40% of developments that have to be “affordable” do not attract CIL or S106 contributions.

 

Additional response to Rushmoor Local Plan

Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Southwood Business Park, Rushmoor Borough, Hampshire.

We have made an additional submission to the Rushmoor Borough Council Local Plan consultation pointing out the absurdity of seeking to protect 96 Ha of employment land when there’s going to be a surplus of 195 Ha of employment land across the Housing Market Area of Hart District, Surrey Heath and Rushmoor Boroughs at the end of the plan period.

This is available as a download for those wishing to add their voice to the consultation.

 

Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan

 

Our first submission and reasoning can be found here and here.

Link

Questions for Hart District Council July Meeting

Protect our green fields

Protect our green fields

There’s another Hart District Council meeting next week on 30 July.  We Heart Hart has tabled some questions about school places and brownfield sites.  This includes asking Hart to consider our 5 point plan for change.

Please feel free to use our questions as inspiration for your own.

Update: I have added two further questions:

  • It appears Hart is now proposing to publish a draft Local Plan prior to the pre-submission version.  Will publication of this draft be accompanied by a Reg 18 consultation and when will the LDS be updated to reflect this change?

HBF calls for Hart to meet Rushmoor’s unmet housing need

Is this what we want Hart to turn into?

Is this what we want Hart to turn into?

The Home Builders Federation (HBF) has responded to Rushmoor’s Local Plan consultation and called for Hart to concrete over its green fields to build all of Rushmoor’s unmet housing need.

Hart is the solution

To ensure that the Council is doing what it can to maximise the effectiveness of the duty to cooperate the Council must approach Hart Council to make sure that it provides land to meet the shortfall arising in Rushmoor. We note in paragraph 4.6 of Topic Paper 2: Housing Delivery that the Council asserts that the duty is not a duty to agree. This suggests a lack of zeal on the part of the Council to ensure that the unmet housing need of Rushmoor is addressed. Even if Hart and Surrey Heath are unable to provide land the three HMA authorities should engage with authorities elsewhere to persuade them to provide land to accommodate the shortfall.

It then goes on to make the silly suggestion that Hart to review its Green Belt, when in fact Hart doesn’t have any Green Belt land.

Reviewing the Green Belt in Hart

The Council must work with Hart to remove land from the Green Belt if this is what is necessary to accommodate the housing shortfall.

The HBF then call on Rushmoor to increase their housing allocation by an arbitrary 10% because the HBF believe more affordable housing should be built.

We consider that a 10% adjustment upwards should be made to the baseline demographic need.

They do not seem to consider the option of house-builders reducing their prices, nor do they mention that part of the reason house prices are so high is because interest rates have remained at 0.5% for around 6 years.

Amazingly, the HBF make no mention at all of brownfield land in their submission, despite Rushmoor seeking to protect 96 Ha of land even though there will be a surplus of around 195 Ha of employment land across the Housing Market Area at the end of the plan period.

It is simply unacceptable for an unelected industry body to seek to override the wishes of local people by asking Hart to concrete over green fields, whilst at the same time ignoring the vast opportunity presented by brownfield sites.

If you would like to make your own submission to then please download the pre-prepared feedback forms below, fill in your details and send them off to [email protected].  The consultation closes on 20 July 2015.

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form
Additional Response to Rushmoor Local Plan
Additional Response to Rushmoor Local Plan

 

Infrastructure costs of over £300m put Winchfield new town plans in doubt

Construction Workers

Construction Workers

A new study by Hart District Council has highlighted significant barriers to future housing delivery in the district. We estimate that the high level costs of meeting these infrastructure gaps might be over £300m.

The study covered 4 areas:

  • Education
  • Transport
  • Utilities
  • Flood Risk

Education was highlighted as having significant barriers to delivery, with a high level cost estimate of £80-100m (higher than the £62m estimate we put together back in February).

Transport was also highlighted as a significant barrier to delivery, but no cost estimate was given.  However, the possibility of needing a new junction on the M3 was discussed.  It is difficult to see how a brand new junction will give much change from £100m, given a new junction at Birmingham airport will cost £250m.  Of course other roads and bridges in the area will also need to be upgraded that we estimate at £35-40m.

The report also discussed railway provision and suggested that the existing railway bridges over the roads in Winchfield would need to be upgraded and that Winchfield station itself may need to be replaced with a new station at Murrell Green.  The report made no mention of the fact that these bridges and Winchfield station itself are now listed on  Hampshire’s Archaeology and Historic Buildings Record.  Amazingly, railways were not considered to be a significant barrier to housing delivery even though no site for a new station has been identified and the costs of such a construction and the new roads that would be needed have not been evaluated. The recent improvements to Fleet station cost >£8m, it is difficult to see how a totally new station, including platforms, buildings, signalling, car parks and new road access would cost less than £25m. The recent Network Rail funding debacle puts such an investment in grave doubt.

Provision of foul water capacity was identified as a significant barrier to housing delivery although no costs were identified.

The potential need to put the existing high voltage electricity lines that cross Winchfield underground was raised. This costs around £20/km, so would probably cost round £50m.  This was not considered to be a significant barrier.

The report did not cover the costs of additional healthcare facilities that would be required to cope with the increased population all these extra houses would create.

Adding all this up, and the total costs will be in excess of £300m.  We have reported before that Hart estimates that there is currently a £78m funding gap for infrastructure and Hampshire estimates a funding gap of £1.9bn across the county. All of the costs above will add to that gap.  It is simply not credible to believe that such large costs will be funded by developer contributions.

The study recommended that further studies be carried out to examine these issues in greater detail:

  • Identify potential implications for infrastructure provision of the Preferred Housing Distribution Strategy (June 2015) which broadly set out a higher level of growth than hitherto within existing settlements
  • Commencement of a full Transport Assessment (TA) potentially utilising the existing HCC North Hampshire Transport Model (NHTM)
  • Commencement of an Integrated Water Management Strategy (IWMS)
  • Continued engagement with HCC (particularly with regard to school place provision) and with South West Trains (SWT) and Network Rail (NR)
  • Consolidation of information into an updated Infrastructure Delivery Schedule (IDS) to support both the emerging local plan and community infrastructure levy (CIL) at public examination
  • Continued engagement with the Enterprise M3 Local Enterprise Partnership (E3LEP)

None of these tasks appear to be identified in the work plan for the Local Plan, so there is little doubt that the Local Plan project is now massively behind schedule.

Government and CPRE call for more building on brownfield sites

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

Empty Offices at Farnborough Aerospace Business Park, Rushmoor Borough, Hampshire.

In response to the Government’s Productivity Plan, announced today, the Campaign for the Protection of Rural England (CPRE) has called for the Government to implement a ‘brownfield first’ rule.

The Government will introduce a new zonal system which will effectively give automatic permission on suitable brownfield sites.  This was welcomed by the CPRE in their statement, but they asked the Government to go further saying:

“To achieve the development we want and need on brownfield land, the Government should implement a ‘brownfield first’ rule at the heart of planning to prioritise urban redevelopment and leave behind the unsustainable status quo – where developers cherry pick green fields for development. Communities must also be involved from the start to ensure good design, and it is desperately important that new developments include a significant amount of affordable housing.”

We Heart Hart wholeheartedly agrees with this approach, and would like to see the combined boroughs of Hart, Surrey Heath and Rushmoor implement these ideas by prioritising building on the 196 hectares of vacant employment land that will remain in the Housing Market Area at the end of the plan period.  In particular, Rushmoor is protecting 96 hectares of employment land, whilst at the same time asking Hart to build 1,600 houses on beautiful green fields.  We think this is madness and it forms one of our arguments opposing the Rushmoor Local Plan.  If you would like to put in your objection, please see our post here and please use the pre-prepared form on the link below.

 

Rushmoor Local Plan Response Form
Rushmoor Local Plan Response Form

 

There are certainly plenty of brownfield sites to be considered:

  • We Heart Hart's Mascot - Bravehart
    We Heart Hart's Mascot - Bravehart